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22 April 2022 GST/HST Interpretation 217998- – […][Calculation of the British Columbia Transitional Tax Rebate (BCTTR)] Unedited CRA Tags ETA Part IX, 296(2.1), New Housing Transition Tax and Rebate Act (BC): Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. GST/HST Rulings Directorate Place de Ville, Tower A, 11th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 217998 [Dear Client] Subject: GST/HST Interpretation […][Calculation of the British Columbia Transitional Tax Rebate (BCTTR)] We are writing in response to […][your correspondence] concerning the treatment of the British Columbia Transitional Tax Rebate (BCTTR) […] for purposes of the Goods and Services Tax/Harmonized Sales tax (GST/HST) and the New Housing Transition Tax (NHTT). ... The GST applies in the rest of Canada at the rate of 5%. […] We understand that a registrant (the Registrant) sold [#] residential properties located in British Columbia during the period [mm/dd/yyyy] to [mm/dd/yyyy]. […] INTERPRETATION REQUESTED […], is the BCTTR an “allowable rebate” for purposes of subsection 296(2.1) of the ETA [when determining the net tax of the Registrant and the NHTT]? ...

FACTS 1. […] (the Landowner) and […] (the Investor) have entered into a written agreement called […] (the Agreement). ... Per section […] of the Agreement, the Investor was responsible for the installation of the solar panels. 5. ... Pursuant to paragraph […] of the Agreement, the Landowner shall be paid the first $[…][X] of revenue earned from the solar project in each year and pursuant to paragraph […] of the Agreement, the Investor shall be paid all remaining revenue. 11. ...

STATEMENT OF FACTS We understand that pursuant to a contract (the Agreement) you entered into with […] (the Corporation) on [mm/dd/yyyy], you provide […]. Under the Agreement, you are paid a fee by the Corporation of $[…] per case to $[…] per case, based on the work involved in the case. ... In a conversation with […] of the […][Province A] GST/HST Rulings office, you advised that clients apply for insurance with a licensed insurer […]. ...

When Company A sells the finished product, it must sell it on a tax-paid basis unless an exemption applies, such as: * The diesel is sold to a licensed wholesaler. * The diesel is sold to a licensed manufacturer who will further manufacture the diesel or where a section 48 authorization exists. * The diesel is sold to an end-user for use in the generation of electricity, except where the electricity so generated is used primarily in the operation of a vehicle. The end-user must provide a certificate. * The diesel is exported from Canada. * The fuel is sold and used as ships’ stores. * The diesel is sold as heating oil. ... Yours truly, Nathalie Robitaille Excise Taxes and Other Levies Unit Excise Duties & Taxes Division Excise and GST/HST Rulings Directorate ...

1 February 1998 GST/HST Interpretation 1998-02-01- Calculation of Penalty & Interest Unedited CRA Tags ETA 280(1) Brian Paynter Program Officer Assessment & Collections Robert Bowman A/Rulings Officer GST/HST Rulings & Interpretations Directorate Subject: Calculation of Penalty & Interest Thank you for your electronic mail message dated September 15, 1997, concerning the application of subsection 280(1) of the Excise Tax Act (ETA) where a registrant requests an adjustment to a previously filed return to correct an error that resulted in an overpayment of a net tax refund to the registrant. ...

RetailCo is […] with stores across Canada selling a wide range of supplies, including food. 4. ... It manufactures and sells to RetailCo a variety of […] (“product”). 5. ... RetailCo, […], coordinates and schedules the agreed-upon demos for and on behalf of USCo by entering the scheduling details into the system. 13. ...

STATEMENT OF FACTS We understand the facts to be as follows: 1. […]. 2. The Product is supplied in […]mL […] bottles. 3. The percentage of volume of natural juices is [greater than 25]% and is comprised of […]. 4. The Product label states the following: […] 5. The Product label states: “Recommended use: […]”. 6. ...

You also provided the following documents: * A third party authorization that authorizes […] (the Representative) to correspond on the Taxpayer’s behalf. * Standard authorization for facsimile transmissions. ... We understand the following: The First Nation is a limited partner of […] (the Company), whose activities are carried out on a reserve. ... Yours truly, Shivam Bagga, CPA Senior Rulings Officer Legislative Policy and Regulatory Affairs Branch FOOTNOTES 1 HYPERLINK " https://decisions.scc-csc.ca/scc-csc/scc-csc/en/item/18781/index.do " References re Greenhouse Gas Pollution Pricing Act, 2021 SCC 11 at para 219. ...

The following documents were provided to us for our consideration: a) [...] used to evidence: • the registration [...] ... The Home Site is defined in Schedule [...] the Homeowner Agreement as the land that has the same legal description as the land identified under subsection [...] of the Purchase Contract. ... Penalty for Nonperformance (subsection [...]) If the Homeowner fails to complete the Development of the Home Site within [...] years from the Possession Date, the Homeowner will be liable to pay to the Corporation $[...]. ...

Services provided by the Corporation include the following: * General healthcare, including health and nursing care, treatment and monitoring of temporary and chronic illness; * 24 hour urgent on-call physician care; * Preventative healthcare including general health teaching, routine physicals, vaccinations and screening for disease; * Diabetes management and treatment services such as insulin initiation and adjudication, follow-up physician instructions and dietician counseling; * […] 8. ... There are [#] individual physicians on staff who collectively work the equivalent to [#] full-time physicians. ... The audited financial statements for the year ended [mm/dd/yyyy], indicate that the Corporation received $[…] from the MOHLTC/[…] Local Health Integration Network as “Community Health Centre” funding. 16. […], the MOHLTC advised that the Corporation is approved as a health service provider, being a Community Health Centre that provides health services […]. ...